Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
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